II.II. UtilityUtility CompanyCompany Practices:Practices: AA SurveySurvey andand SampleSample ResponseResponse

ith government lagging behind in the protection of public health and the environment from the impact of hazardous pesticides like preserva- tives, it is often the private sector that steps in to take action that is protective at the community, state and national level. In the case of pentachlorophe- WWWnol, with 93 percent of all penta used on utility poles, utility The questions addressed in the survey include: companies are critical decision mak ers on this key pub- lic health and environmental issue. For example, some What are the environmental practices employed by utili- manufacturers in the food industry have chosen to elimi- ties across the and Canada? nate the use of specific pesticides or practices in response to safety con- How many and what types of util- cerns that have not been adequately After Beyond Pesti- ity poles are in use in communities? regulated by EPA. cides/NCAMP’s survey was mailed to 3,000 Are utility companies in the habit To assess the role that utility companies of retreating aging wood utility poles? can and do play in addressing the haz- utilities, the American Wood Preservers Insti- ards of wood preservatives including To what extent do utilities store pentachlorophenol, Beyond Pesticides/ tute (AWPI) immedi- on-site treated poles in the commu- NCAMP developed and distributed a ately started a cam- nity? survey to over 3,000 utilities to analyze paign against the sur- their knowledge of the problem and vey, urging utility ex- What happens to treated poles steps that they have taken or are plan- after they are taken out of service? ecutives in a memo ning to take to address the hazards of Are they disposed of as hazardous wood preservative-treated utility poles. from AWPI’s president waste? This survey follows the release of Be- not to cooperate. yond Pesticides/NCAMP’s Do the utilities currently use or do breaking report Poison Poles: A Report they have plans to use alternatives to the poisonous treated About Their Toxic Trail and the Safer Alternatives , in 1997. wood utility poles? Poison Poles introduced the hazards of the wood preserv- ing chemicals and the extent of their use to an unaware public. Since that time, EPA has committed to conducting The survey (See appendix B) was sent to over 3,000 utili- a review of the hazards of wood preservatives under its ties across the U.S. and Canada. The survey asks straight- reregistration process and has recently released prelimi- forward questions to which the public has a right to answers. nary scientific analyses indicating serious hazards asso- None of this information should be considered secret, given ciated with the use of pentachlorophenol in utility poles. In the fact that utilities are handling and possibly exposing the addition, since 1997 EPA has calculated the excessive public and the environment to hazardous materials. dioxin contamination associated with wood preservative- treated utility poles. The wood treatment industry apparently feels differently.

POLE POLLUTION 9 After Beyond Pesticides/NCAMP’s survey was mailed to only considers alternative poisons. The EPA chooses the utilities, the American Wood Preservers Institute not to ask the simple and obvious question: Has this poi- (AWPI) immediately started a campaign against the sur- sonous chemical been rendered obsolete and, therefore, vey, urging utility executives in a memo from AWPI’s presi- unnecessary as a result of new, less hazardous, cost ef- dent, not to cooperate. (See Appendix C) This is troubling fective technologies on the market? and telling, since AWPI has effectively influenced EPA decision making on this issue over the last two and a half Secondly, there is a long established culture in the utility decades behind closed doors. On one level, AWPI’s re- industry to use wood utility poles. Without regulatory ac- sponse is surprising, given that the organization claims tion on the part of the EPA, utility companies have had no that penta and the other wood preservatives pose a mini- reason to change their practices. In addition, any change mal threat to human and environmental health. 1 What in industry practice does require an investment as work- then does the AWPI have to hide from the public? Those ers are retrained. However, this industry investment is utilities that chose to ignore the AWPI and responded are small in comparison to the savings in human and environ- taking the initial steps toward engaging in a public discus- mental health costs that could be realized with an increase sion on this important topic. in the use of alternative utility pole materials.

Despite AWPI’s efforts, the survey has generated a pre- Third, the availability and economy of nonwood utility liminary 39 responses from utilities that cover 24 states poles has changed radically in the recent past. Steel, and Canada and control nearly one mil- lion poles in their service area. These utili- Table II. Utilities From 24 States and Canada ties collectively serve an area of over Responding to the Utility Pole Survey 38,886 square miles or at least 57,000 road/pole miles. The respondents in- Arkansas Missouri Colorado Montana clude smaller utilities across the U.S. and Connecticut North Carolina Canada and do not include any of the top Georgia Nebraska 100 utility companies, which have appar- Hawaii New Hampshire ently heeded AWPI’s advice in not shar- Iowa New Mexico Illinois Ohio ing basic information with the public. Indiana Oregon Kansas Tennessee Survey Overview Louisiana Texas Massachusetts Utah Minnesota Wisconsin Toxic, chemically treated wood poles are favored by the utilities; 98.5 percent of the poles in our survey are chemically treated wood poles. concrete and composite poles are readily available, last Penta stands out as the chemical treatment of choice longer and do not require remediation expense. In addi- among the utility respondents; at least 56 percent of the tion, steel poles taken out of service are recyclable, so poles are treated with penta, 20 percent with , utility companies can actually realize a return when dis- and 14 percent with chromium arsenate (CCA). posing of steel poles. Despite this, most utilities are nei- Only 1.5 percent of poles in our survey were made with ther using nor considering nonwood utility poles. alternative materials. The major findings of the utility survey focus on the follow- There are a number of possible explanations for the very ing questions. small number of alternative material poles in use. First and foremost, the EPA has failed to adequately protect How prevalent is a particular practice among the utility the public through its regulation of the wood preserva- industry? tives. When the EPA considers alternatives during its risk analysis of a toxic chemical it does not include alternative What are the problems associated with those prac- technologies in that equation. Believe it or not, the EPA tices?

10 POLE POLLUTION How will moving away from wood utility poles solve Retreatment of Poles In Service those problems? The survey found that 34 percent of utilities retreat wood Utility Pole Storage poles in an effort to increase their life span. Groundline remediation of poles not only introduces a fresh dose of The study finds that 87 percent of the utilities that responded toxic chemicals to the environment around the pole, it also stored chemically treated wood utility poles on site. One increases the cost of using treated wood poles. These are utility reports storing as many as 7,200 poles at given time two additional reasons for a shift from the use of wood poles at their facility. A typical utility pole of to the use of alternatives. 12 inches in diameter and 45 feet in A typical utility pole of 12 length contains 40 pounds of penta. 2 According to EPA’s calculations, inches in diameter and 45 A utility yard storing 7,200 such poles the single highest risk of cancer from represents 288,000 pounds (144 tons) feet in length contains 40 exposure to penta belongs to those of penta that could leach into the soil pounds of penta. A utility people hired to apply liquid penta and ground water. yard storing 7,200 such formulation for groundline poles represents 288,000 remediation. EPA has determined Bell Canada, in 1988, conducted a that these unfortunate men and pounds (144 tons) of penta study to determine whether soil and women have a 3.4 chance in 1 to groundwater in its storage yards were that could leach into the suffer from cancer due to penta. 8 contaminated by penta and/or an- soil and ground water. 3.4 out of 1? How is that possible? other wood preservative, CCA. In Que- Beyond Pesticides/NCAMP has bec, where the company uses mostly penta-treated poles, been able to make sense out of that particular datum in the clean-up criteria, or levels determined acceptable, were only one way: people that apply liquid penta to in-service exceeded by factors as high as 100 at 10 out of 14 sites. 3 poles have an 100% chance of getting cancer and be- Another Canadian study measured the amount of penta come contaminated to the point that they then expose their leaching out of a pile of 15 poles under natural colleagues, friends and family to penta, leading to an addi- rainfall conditions in . The level of penta tional 2.4 cases of cancer. This is an extraordinary risk. released from these poles was relatively constant through- out the study period of four months, ranging from 1.57-2.85 Neither utility lines made from alternative materials nor bur- 4 mg/L rainfall. ied utility lines require remediation treatment. Our research indicates a range of $30 to $50 per pole for remedial treat- ment. Any cost/benefit analysis conducted by the utility in- It is clear that penta and its contaminants do leach from dustry must include an assessment of the human health utility poles, both from the poles stored in pole yard and cost, the environmental cost and the economic cost of those in service. A study conducted by the retreatment of wood poles. Research Institute (EPRI) measured soil adjacent to utility poles in service. EPRI found levels of penta in the soil Disposal of Treated Poles around the poles as high as 100 mg/kg or 100 parts per million (ppm). 5 EPRI also evaluated the leaching of penta One of the most disturbing findings of the survey is what into lower depths of soil around 168 in-service wood utility appears to be the standard utility industry practice of giv- poles and found that penta residues were relatively con- ing away or selling used chemically treated wood utility stant to 48 inches; 6 maximum levels were above 500 mg/ poles to the public. Over 68 percent of the utilities dispose kg. It has also been shown that dioxins are leaching out of of poles in this way. Why is this disturbing? Because the penta treated wood utility poles. Significant levels of dioxin public has not been informed of the risks to their health were measured in soil samples taken from around penta- associated from contact with that poisonous wood. treated poles, with detectable levels of dioxin found 20 cen- timeters from the poles. 7 When discarded poles are cut into pieces, the saw dust

POLE POLLUTION 11 can end up on the skin and in the lungs of the handy- Cost Analysis of Alternative Methods/Poles person and his or her family. That newly created becomes fence posts, garden retainers, or a jungle gym Alternative methods of carrying utility lines carry far less for children. risk to human health and the environment. Where burying utility lines may not be feasible, alternative materials such A utility in Topeka, Kansas, Western Resources, actually as steel, concrete, and composite are cost effective ma- won an award from the Kansas Department of Health and terials for utility poles. Environment for providing toxic lumber for public projects (See Appendix E). Instead of disposing of their poles in An important cost that is eliminated with the use of alterna- an appropriate landfill, the toxic lumber was converted tive material poles is the environmental and economic into an environmental classroom shelter, a bird viewing cost of retreatment. As outlined above, groundline blind, and bird boxes, to name just a few. remediation introduces a fresh dose of chemical wood preservatives into the environment where it can contami- Only one of the utilities that replied to the survey provided nate our soil, water and air. This route of environmental a Material Safety Data Sheet (MSDS) along with the used contamination also costs the utility companies money. Not poles to consumers. (See Appendix D). The MSDS states only do alternative pole materials not need retreatment that penta “has been found to have toxic effects in labora- but their useful life span is longer than for wood. tory animals. . . Exposure to treated wood should be kept to a minimum. . .Exposure to penta during pregnancy Research shows that concrete poles can last from 80 to should be avoided. . .Penta contains trace amounts of 100 years in service. 9 According to sources at Interna- Hexa, Hepta, and Octochlorodibenzo-p-dioxins, Hexa, tional Utility Structures, Inc, manufacturers of steel poles, Hepta, and Octachlorodibenzofurans, and steel poles have useful life spans of 80 years. Fiberglass Hexachlorobenzene. The State of California has listed poles, according to one manufacturer, Shakespeare ® , Hexachlorodibenzo-p-dioxin and Hexachlorobenzene as have in-service life spans of up to 80 years. Penta-treated chemicals known to the State to cause cancer.” It is inter- wood poles, on the other hand, have life expectancies of esting to note that this same utility requires that consum- 35 years. 10 ers of the used poles sign an agreement freeing the utility from liability for any harm caused by the poles. An additional benefit of steel is its ability to be recycled. Utility companies can actually realize a return when they 23 percent of utilities disposed of their discarded wood sell their old steel poles for scrap to be recycled. poles in landfills but only 5 percent treat the poles as haz- ardous waste. In regular landfills the chemicals inside the Under the current regulatory regime utility companies are poles are free to leach out into the environment, contami- free to externalize the costs to human health. With appro- nating our soil, groundwater and eventually our bodies priate regulation of penta, and the other wood preserva- (See research cited above under storage). Despite lim- tives, utility companies will be forced to realize these costs. ited legal requirements in this area, Beyond Pesticides believes that the only appropriate way to dispose of chemi- cally treated wood poles is in certified hazardous waste landfills.

Use of Alternative Pole Materials

Survey responses indicate that less than two percent of utilities are using alternative pole materials, including steel, concrete and composite. Futhermore, all the respondents indicate that they have no plans to consider switching in the future to poles constructed out of alternative materials.

12 POLE POLLUTION